If my materials are exempt (yarn for example) do I need to label?

[Former_Member]

I spent a little time looking around and am not sure about this.

Right now what I make that is for kids has exempt materials (I know that may not be permanent.) So, do I still need to have permanent labels?

[Former_Member]

Labeling requirements are separate from testing requirements. Yes, you have to label.

Labeling requirements have actually been in place long before CPSIA.....

[Former_Member]

I do already attach a tag to be removed by the purchaser with information like materials used, care instructions, country of origin and so forth. However, I am certain it would not be considered a permanent label and it does not have the other information in the CPSIA guidelines.

[Former_Member]

Sounds like you're talking about a hangtag...which is not acceptable for CPSIA and I'm not even sure it's adequate under current laws.

You may wish to browse on Fashion Incubator which is an excellent resource for clothing manufacturers. And here's the FTC wesbite for some labeling information and requirements:
http://www.ftc.gov/os/statutes/textilejump.shtm

[Former_Member]

Thanks, but I don't make clothing. I am off to check more on this on my own.

[Former_Member]

Well, if you're not making clothing, the FTC might not apply but CPSIA still does :) And there's not a whole lot of guidance yet on CPSIA labeling. You can see here: http://www.cpsc.gov/about/cpsia/faq/faq.html#sect103

[TerriesStudio]

Thank you, Buggalove! I've been worried about a product that I am designing. I went to the site you suggested and found that if I sell my product for 13 years and older, I should be safe. My item is basically for preteens or teens, but I think adults will use it too.

[Former_Member]

TerrieB2 - the problem is that you may decide that the item is for 13 and up but CPSC can still step in using their chart of "age appropriateness" and say you are in violation. Just putting an age disclaimer on an item is not allowed to determine the age the item is to be sold to or used by.

[TerriesStudio]

Ohhhh...kay... SO I'll have to do some more thinking. Do you have to submit your product to them for a rating or something? Do they watch sites like this for products that need to comply? In other words -- how do they know about my item and whether it complies? (Sorry to be so dumb about it!)

[StitchMorgantown]

I too am very confused about all of this hub-bub. I've read over the requirements a while back, but can someone do a guide for dummies?

[Former_Member]

If someone else determines the age for use, how do you know if you need labeling?

[Former_Member]

Here are the criteria by which the CPSC will determine if a product is a children’s product:

#1 - A statement by the manufacturer about the intended use of the product, if such a statement is reasonable

#2 - Is the product represented in it’s packaging, display, promotion, or advertising as appropriate for use by children 12 years old or younger

#3 - Is the product commonly recognized by consumers as being intended for use by a child 12 or younger

#4 - The Age Determination Guidelines issued by the commission staff in September 2002

[StudioYTE]

marking

[Former_Member]

marking

[FayeMaloneDesigns]

15PiecesofFlair says:
I too am very confused about all of this hub-bub. I've read over the requirements a while back, but can someone do a guide for dummies?


15pieces...Unfortunately, this law was written by dummies. If they were smart, and had common sense they would have realized how convoluted, unworkable and onerious this law was. But they don't really give a darm.

[Former_Member]

Thanks, BuggaLove!

[Former_Member]

FayeMaloneDesigns says:
15PiecesofFlair says:
I too am very confused about all of this hub-bub. I've read over the requirements a while back, but can someone do a guide for dummies?


15pieces...Unfortunately, this law was written by dummies.
***************************
LOL!

[Former_Member]

amen... fayemalonedesigns

[Former_Member]

I make baby booties and they are small how do you label them, I was given this suggestion, using plastic bags and place the list of materials , origin, batch # etc. on the list and place in a plastic bag which I am toying with a little carying case to go with each pair of booties that I make, I am allso looking at the same idea for my hairties that I make.

[Former_Member]

Frogbowler - I make hairclips which are also too small to have an affixed, permanent tag. I posed this as a concern in another forum. Check out page 4/5 - it talks about being able to affix an adhesive label to packaging for small items.

http://www.etsy.com/forums_thread.php?thread_id=6201814

However, I went to the CPSC website just now and saw this tidbit of information (see the third question down at this link ... http://www.cpsc.gov/about/cpsia/faq/103faq.html#domestic):

Q: Could hangtags and adhesive labels be used as tracking labels for textile-type items?

A: No. The law requires that markings with the specified information be permanent. Hangtags and adhesive labels are not permanent.

I used this link (http://www.cpsc.gov/cgibin/newleg.aspx) to pose the specific question around labeling for small items. If I hear back, I'll post the response in this thread.

[Former_Member]

Since no 2 labels will be the same b/c of batch number and such, I don't understand how we can create a different permanent label for each item. I doubt printing label companies would take orders for 1 each of tons of custom labels, besides the cost even if they do.

[ByNanasHands]

Leave a blank space and enter your "batch" number with perm. marker...such as the date of creation, mm/dd/year etc.....

[Former_Member]

meganbalaban says:
Frogbowler - I make hairclips which are also too small to have an affixed, permanent tag. I posed this as a concern in another forum. Check out page 4/5 - it talks about being able to affix an adhesive label to packaging for small items.

http://www.etsy.com/forums_thread.php?thread_id=6201814

However, I went to the CPSC website just now and saw this tidbit of information (see the third question down at this link ... http://www.cpsc.gov/about/cpsia/faq/103faq.html#domestic):

Q: Could hangtags and adhesive labels be used as tracking labels for textile-type items?

A: No. The law requires that markings with the specified information be permanent. Hangtags and adhesive labels are not permanent.

I used this link (http://www.cpsc.gov/cgibin/newleg.aspx) to pose the specific question around labeling for small items. If I hear back, I'll post the response in this thread.

******************************************************

You likely will not hear back personally with an answer regarding that because currently there is no answer to that question. Congress included the phrase "to the extent practicable" in their wording regarding labeling. The CPSC has not provided any guidance regarding what that means or which products that might apply to, in fact we are waiting for some sort of labeling guidance from them at all.

My blog on labeling (not all inclusive, but a simple start):
http://buggalove.blogspot.com/2009/06/labeling-requirements-for-cpsia.html

[Former_Member]

marking

[Former_Member]

Marking...this is so confusing. I wish the people that wrote the laws would think for 2 seconds about what they are creating. It seems like the law has strayed away from what it was intended to be.